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liability for 1992.
E. Respondent’s Efforts To Schedule a Hearing
On January 30, 2001, and May 1, 2001, Appeals Officer Joe
Gurnaby issued letters to petitioner requesting that he contact
the Appeals Office to arrange an administrative hearing at a
mutually convenient time. Petitioner did not contact the Appeals
Office with regard to either letter.
F. Respondent’s Notice of Determination
On June 4, 2001, Appeals Officer Gurnaby prepared an Appeals
Office transmittal memorandum. The memorandum stated that the
Appeals officer reviewed an Internal Revenue Service TXMODA
transcript of account dated December 21, 2000, and determined
that respondent had complied with all applicable legal
requirements with regard to the assessment of petitioner’s tax
liability for 1992.3 A copy of the transcript of account was
attached as an exhibit to the Declaration that accompanied
respondent’s Motion for Summary Judgment.
On June 8, 2001, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330. The notice stated that the Appeals Office had
3 A TXMODA transcript contains current account information
obtained from respondent’s master file. “TXMODA” is the command
code (CC) that is entered into respondent’s integrated data
retrieval system (IDRS) to obtain the transcript. IDRS is
essentially the interface between respondent’s employees and
respondent’s various computer systems.
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